2025 Draft Simplified ESRS ESRS 1 ESRS 2 ESRS E1 ESRS E2 ESRS E3 ESRS E4 ESRS E5 ESRS S1 ESRS S2 ESRS S3 ESRS S4 ESRS G1 ESRS 1

(6 amended) ESRS 1 General Requirements explains drafting conventions and sets out general requirements for identifying the undertaking’s material impacts, risks and opportunities, and for preparing and presenting information to be reported. It also sets out general requirements for the basis of preparation of the sustainability statement.

(5 amended) The undertaking shall apply this Standard in conjunction with ESRS 2 General Disclosures (both referred to as ‘cross-cutting standards’) and with the topical standards.

(7 amended) ESRS 2 General Disclosures establishes Disclosure Requirements (DRs) on the information that the undertaking shall provide at a general level across all the topics to which its material impacts, risks, and opportunities relate, covering the reporting areas listed in paragraph 5.

(8 amended) Topical standards address topics and sub-topics, complementing the requirements provided in ESRS 2 General Disclosures, and encompass the reporting areas listed in paragraph 5. The table in Appendix A List of topics provides an overview of the topics and sub-topics covered by topical standards.

(11 amended) If the undertaking concludes that a topic related to material impact, risk or opportunity, is not covered, or not covered with sufficient granularity, by an ESRS, it shall provide entity-specific disclosures taking account of the provisions on fair presentation in Chapter 2. This may be the case due to sectorial specificities or other facts and circumstances relevant to the undertaking itself.

(AR 4(b) amended) When developing its entity-specific disclosures, the undertaking shall consider comparability over time and with other undertakings that operate in the same sector(s).

(15) Throughout ESRS, the terms that are defined in the Glossary of Definitions (Annex II of Delegated Regulation (EU) 2023/2772) are denoted in bold italic, except when a defined term is used more than once in the same paragraph. 

(2 amended) ESRS use the terms sustainability ‘topic’ and ‘sub-topic’ understood as synonymous with the terms ‘sustainability matters’ or ‘sustainability factors’ as used in the Accounting Directive (Directive 2013/34/EU). Disclosures in ESRS are structured into topics. A topic is further disaggregated into sub-topics. In ESRS, the term topic (in bold italic) is used to indicate either a topic or a sub-topic depending on the most appropriate level of granularity needed to meet the respective disclosure objectives.

(14) In all ESRS:

(new) Material impacts, risks and opportunities reported in the sustainability statement are understood to be the same as the undertaking’s principal impacts, risks and opportunities referred to in the Accounting Directive (Directive 2013/34/EU).

(16 amended) The structure of information in ESRS is based on ‘Disclosure Requirements’ (DRs). Each DR consists of one or more distinct datapoints. DRs are signaled by the terms ‘shall disclose’, ‘shall include’, ‘shall report’, ‘shall describe’ and ‘shall explain’ to indicate that an information is prescribed, subject to materiality of information (see paragraphs 23 and 24).

(17 amended) ESRS contain mandatory ‘Application Requirements’ (ARs) that support the application of, and have the same authority as, the requirements prescribed in the main body of the standards. ARs in ESRS 2 General Disclosures and in topical standards support the preparation of disclosures that meet the qualitative characteristics of information (see Appendix B) (18 amended). ARs use the term ‘shall consider’ to indicate issues, resources or methodologies that the undertaking is expected to take into account or to use in the preparation of a given disclosure. ARs also include presentation options, indicating that a given piece of information may be provided in tabular form, as narrative text or in other types of presentation options.

Double materiality has two dimensions: impact materiality and financial materiality and the undertaking shall consider how they interact. An impact can be financially material from the start or become financially material, when it is reasonably expected to affect the undertaking’s financial performance, financial position, cash flows, its access to finance or the cost of capital over the short, medium or long term. Impacts can be material exclusively from an impact perspective, irrespective of whether they are financially material.

In general, the starting point is the assessment of impacts. The undertaking shall as well evaluate whether there are material risks or opportunities that are not related to the undertaking’s impacts, such as physical risks.

(42 amended) The undertaking shall determine which impacts, risks or opportunities are material, based on the criteria in Chapters 3.2.1 and 3.2.2, and supported by appropriate qualitative considerations and quantitative thresholds.

(62 amended) The sustainability statement shall be for the same reporting undertaking as for the financial statements. If the parent undertaking prepares consolidated financial statements, the sustainability statement shall be for the parent and its subsidiaries in accordance with the applicable accounting requirements. This does not apply if the undertaking is not required to prepare financial statements or if its consolidated sustainability reporting is prepared in accordance with Article 48(i) of Directive 2013/34/EU.

(new) In the case of group reporting, the reporting undertaking usually - except for specific circumstances, such as leasing and assets that are held by the undertaking’s long-term employee benefit schemes - considers as part of own operations: the assets, liabilities, revenues and expenses of the parent undertaking and its subsidiaries, located in or outside the EU, as determined in accordance with the applicable accounting requirements. Paragraphs 63 to 76 provide further provisions and exceptions for determining the reporting boundaries of own operations and upstream and downstream value chain. In addition, the undertaking may exclude from the sustainability reporting boundary a subsidiary that has been excluded from the scope of the consolidated financial statements due to its non-materiality from a financial perspective, unless there are specific facts and circumstances that expose the group to impacts arising from such subsidiary, that meet the group’s materiality thresholds.

(63 amended) To the extent necessary for an understanding of the undertaking’s material impacts, risks and opportunities and to meet the qualitative characteristics of information (see Appendix B), the reported information shall be extended beyond own operations to cover material impacts, risks and opportunities connected with the undertaking through its direct and indirect business relationships in the upstream and downstream value chain (value chain information), without prejudice to the relief on acquisitions in Chapter 5.4.

(63 amended) The undertaking shall include material upstream and downstream value chain information in accordance with the outcome of its double materiality assessment as described in this standard and any specific requirements related to the upstream and downstream value chain in other ESRS.

Applying paragraph 64 does not require information on each and every actor in the upstream and downstream value chain but only the inclusion of material information.

(69 amended) To identify material impacts, risks or opportunities that are connected with the undertaking through its business relationships in the upstream and downstream value chain, and to report on them, the undertaking may use information collected directly from counterparties in the upstream and downstream value chain, or it may use estimates, depending on practicability and reliability considerations related to the necessary input. When developing estimates, the undertaking may use internal and external information, such as data from indirect sources, sector-average data, sample analyses, market and peer groups data, spend-based data or other proxies.

(67 amended) When applying paragraph 66, the undertaking is not expected to collect from other undertakings in its upstream and downstream value chain information that exceeds any limits set by relevant EU law and regulation. This limitation also applies to non-EU undertakings in the upstream and downstream value chain of the reporting undertaking.

(64 amended) Different impacts, risks or opportunities can be material in relation to different parts of the undertaking’s upstream and downstream value chain.

(71 amended) The information reported about policies, actions and targets shall include upstream or downstream value chain information only to the extent that the value chain is within the scope of the undertaking’s policies, actions and targets.

(new) Investments, including shareholding positions in associates and joint ventures, are treated as business relationships.

(67 amended) Without prejudice to the relief in paragraph 93, in some cases, associates or joint ventures that are accounted for under the equity method are also part of the undertaking’s upstream and downstream value chain beyond the shareholding relationship, such as when they are also suppliers or customers. In these cases, the undertaking shall disclose information related to these supply or customer relationship, in accordance with paragraph 63, consistent with the approach adopted for similar business relationships. In these cases, when determining metrics, the data of the associate or joint venture is not limited to the share of equity held, but it shall reflect the impacts, risks and opportunities that are connected with the undertaking through the supply or customer relationship. This means that the undertaking considers both its relationship as investor in the associate or joint venture and its supply or customer relationship with them.

(new) Impacts, risks and opportunities relating to a leased asset might have different sources, depending on whether they result from the use of the asset or from its ownership. The lessee is using the leased asset, and shall report the impacts connected with the use of the asset in its own operations during the lease period. The lessor provides the right to use the asset to the lessee, and shall reports the impacts connected with the use of the asset as part of its downstream value chain. Whether risks and opportunities relating to a leased asset, as well as impacts other than those connected with the use of the leased asset, accrue to the lessor or the lessee depends on the provisions of the lease contract, which should be reflected in the reported information.

(new) The impacts, risks or opportunities arising from assets that are held by the undertaking’s long-term employee benefit schemes are connected with the undertaking through its business relationships in the value chain.

(new) The provisions of paragraph 72 and 73 take precedence over topical standards including over the provisions in ESRS E1-8.

(new) If the undertaking acquires a subsidiary or a business in the reporting period, it may defer the inclusion of the subsidiary or business in the materiality assessment and in the sustainability statement to the subsequent reporting period. If the undertaking loses control over a subsidiary or business in the reporting period, it may adjust the scope of the materiality assessment and the reporting boundary as from the beginning of the current reporting period.

(new) If the undertaking uses the relief of paragraph 75, it shall use available information to disclose significant events that affected during the reporting period the subsidiary or business acquired or sold since acquisition or until disposal, if this has an effect on the group’s exposure to material impacts, risks and opportunities.

(73 amended) The reporting period for the undertaking’s sustainability statement – including for the calculation of metrics – shall be consistent with that of its financial statements.

(75) A base year is the historical reference date or period for which information is available and against which subsequent information can be compared over time.

(76) The undertaking shall present comparative information in respect of the base year for metrics reported in the current period when reporting progress towards a target unless the relevant DR specifically requires otherwise. If milestones between the base year and the reporting period have been reached, reporting about these achievements is useful contextual information.

(77) When preparing its sustainability statement, the undertaking shall adopt the following time intervals as of the end of the reporting period:

(78) The undertaking shall use additional breakdowns for a long-term time horizon if impacts or actions are expected over a period longer than five years as adding such a breakdown provides relevant information.

(80) The undertaking may adopt a different definition for medium- or long-term time horizons if the use of medium- or long-term horizons defined in paragraph 80 results in non-relevant information. This may happen if the undertaking uses a different definition for (a) its processes of identification and management of material impacts, risks and opportunities or (b) its actions and targets. These circumstances may be due to industry-specific characteristics, such as cash flow and business cycles or planning horizons typically used in the sector for decision-making, the expected duration of capital investments, the time horizons over which users conduct their assessments.

(81) References to ‘short term’, ‘medium term’ and ‘long term’ in ESRS refer to time horizons as determined by the undertaking in accordance with the provisions in paragraphs 80 – 82.

(83) The undertaking shall disclose comparative information in respect of the previous period for all quantitative metrics and amounts. If relevant to an understanding of the current period’s sustainability statement, it is also required to disclose comparative information for narrative disclosures.

(95) The definition and calculation of metrics, including metrics used to set targets and monitor progress towards those targets, shall be consistent over time. The undertaking shall provide contextual information and revised comparative figures unless it is impracticable to do so if it has:

(85 amended) If it is impracticable to revise comparative information for metrics for one or more prior periods, the undertaking shall disclose this fact.

(86) When an ESRS requires the undertaking to present more than one comparative period for a metric or datapoint, the requirements of that ESRS shall prevail.

(84 amended) For metrics and monetary amounts:

(88 amended) The undertaking shall disclose information to enable users to understand:

(91) Some ESRS require the disclosure of information that have uncertain outcomes, such as explanations about possible future events. In judging whether information about such possible future events is material, the undertaking shall refer to the criteria in Chapter 3.2.2 and consider:

(new) The undertaking may exclude activities from metric calculations if, due to their nature, they are not  a significant driver of the impacts, risks or opportunities that the metric purports to represent, and if their exclusion from the calculation is not expected to impair the relevance and faithful representation of the reported information. The undertaking shall disclose if this relief is used and include any relevant information to enable users to understand the scope limitations resulting from it.

(new) Except when reporting ESRS E1-8 metrics, if the undertaking can provide without incurring undue cost or effort reliable direct or estimated data only for an objectively defined part of its own operations or its upstream or downstream value chain, it shall disclose that it has identified material impacts, risks or opportunities but that the corresponding metric can currently only be reported on a partial reporting scope or for a subset of the value chain. In this circumstance, the undertaking shall disclose the actions it has taken to increase the coverage and quality of reported information in future periods and the progress made compared to the previous period. The coverage of reported information is expected to increase over time, particularly for metrics in own operations. This paragraph applies without prejudice to the applicability of the provisions in Sub-Chapter 7.4.

(new) The undertaking may exclude joint operations over which it does not have operational control from the scope of the calculation for environmental metrics reported in accordance with ESRS E2 Pollution, ESRS E3 Water, ESRS E4 Biodiversity and Ecosystems and ESRS E5 Resource Use and Circular Economy. The undertaking shall disclose if this relief is being used and include any relevant information to allow an understanding of the scope limitations resulting from it. In this circumstance, the undertaking shall disclose the actions it has taken to increase the coverage and quality of reported information in future periods and the progress made compared to the previous period.

(89) The undertaking shall use all reasonable and supportable information that is available to the undertaking at the reporting date without undue cost or effort:

(new) The assessment of what constitutes undue cost or effort depends on the undertaking’s specific circumstances and requires a balanced consideration of the costs for the undertaking and the benefits of the resulting information for users.

(new) Reasonable and supportable information that is available to the undertaking without undue cost or effort is subject to reassessment for each reporting period. It reflects the results of the undertaking's past actions to improve data availability or the higher availability of external information. As a result, availability of information is expected to improve over time.

(93) If, after the reporting period but before the management report is authorised for issue, the undertaking receives information providing evidence or insights about conditions that existed at the end of the reporting period, the undertaking shall update its disclosures in light of the new information.

(94) The undertaking shall disclose information about material transactions, other events and conditions that occur after the end of the reporting period but before the date on which the management report is authorised for issue and provide narrative information indicating the existence, nature and potential consequences of these post-year events.

(96) The undertaking shall correct material prior period errors by restating the comparative amounts for the prior period(s) disclosed unless it is impracticable to do so. This requirement does not extend to reporting periods before the first year of application of ESRS by the undertaking.

(99) Potential reporting period errors discovered in the same reporting period are corrected before the sustainability statement is authorised for issue. However, material errors are sometimes not discovered until a subsequent period. In case of material errors discovered in a subsequent period, if it is impracticable to determine the effect of an error on all prior periods presented, the undertaking shall restate the comparative information to correct the error from the earliest date practicable.

(new) The undertaking is relieved from disclosing qualitative and quantitative information required by an ESRS if applicable Union law and regulations prohibits the undertaking from disclosing or allows the undertaking to omit such disclosure. If the undertaking omits material information for that reason, it shall identify the type of information not disclosed and explain the source of the restriction.

(107) If the undertaking omits information in accordance with paragraph 101, it shall comply with the DR in question by disclosing all other required information. (108) The undertaking shall make every reasonable effort to ensure that beyond this omission, the overall relevance of the disclosure in question is not impaired.

(109 amended) When reporting on material opportunities, the disclosure shall consist of descriptive information allowing users to understand the opportunities. The undertaking shall not report general opportunities for the sector but only opportunities that are currently being pursued or incorporated in its general strategy. The provisions on financial effects in ESRS 2 General Disclosures apply when reporting on material opportunities.  

(110 amended) The undertaking shall present all the disclosures required by ESRS within a dedicated section of the management report identified as the undertaking’s sustainability statement which also includes those incorporated by reference in accordance with Chapter 9.3.

(111) Sustainability information shall be presented:

(115 amended) The undertaking shall structure its sustainability statement in four parts in the following order: general information, environmental information, social information and governance information. It may use appendices or separate sub-parts in accordance with paragraphs 108 – 112.

(113 amended) If the undertaking prepares disclosures pursuant to Article 8 of Regulation (EU) 2020/852 of the European Parliament and the Council and to the Commission Delegated Regulations, it is required to include them in its sustainability statement, and may do so in a separate appendix within the management report. These disclosures are not subject to the provisions of ESRS, with the exception of this paragraph.

(114 amended) The undertaking may include in its sustainability statement supplementary information stemming from (i) other legislation which requires it to disclose sustainability information, or (ii) generally accepted reporting standards or frameworks, including non-mandatory guidance and sector-specific guidance, published by other standard setting bodies (such as by the Global Reporting Initiative), even if that information is not material. Such information shall be clearly identified with an appropriate reference to the related legislation, standard or framework.

(new) If needed to meet the data demands of a specific user, the undertaking may include in its sustainability statement supplementary disclosures that are not material. Such information shall be clearly identified as not resulting from the materiality assessment.

(new) Disclosures made in accordance with paragraphs 108 and 109 shall provide a faithful representation of the aspects they intend to represent and shall be presented in a way that does not obscure material information.

(new) The undertaking may provide an executive summary in the sustainability statement which includes the key messages about its material environmental, social and governance impacts, risks or opportunities and their management. The content and presentation of this executive summary shall meet the qualitative characteristics of information and is an integral part of the sustainability statement prepared in accordance with the provisions of ESRS. Alternatively, the undertaking may incorporate information by reference to an executive summary placed outside its sustainability statement, such as in another section of the management report, provided that it meets the conditions for incorporation by reference (see Sub-Chapter 9.3).

(new) The undertaking may use appendices or separate sub-parts in its sustainability statement:

(118 amended) The undertaking shall provide information that enables users of its sustainability statement to understand the connections:

(new) Repeating the same information within the sustainability statement may obscure material information and impair the provision of concise and understandable information. If the same information is relevant to more than one DR, the undertaking may present the information where it considers it to be most relevant and cross-refer to that location as appropriate.

(119) Provided that the conditions in paragraph 119 are met, information or a specific datapoint prescribed by a DR may be incorporated in the sustainability statement by cross-reference to:

(120 amended) The undertaking may incorporate information by reference to the documents, or part of the documents, listed in paragraph 118, provided that the information incorporated by reference:

(121) Provided that the conditions established in paragraph 119 are met, information prescribed by an DR or datapoint may be incorporated in the sustainability statement by reference to the undertaking’s report prepared in accordance with the EU Eco-Management and Audit Scheme Regulation (EU) No 1221/2009. In this case, the undertaking shall ensure that the information incorporated by reference is produced using the same basis for preparation of ESRS information, including scope of consolidation and treatment of upstream and downstream value chain information.

(122 amended) The undertaking shall consider the overall cohesiveness of the reported information and ensure that the incorporation by reference does not impair the readability of the sustainability statement.

(136) ‘Wave one’ undertakings, as defined in paragraph 123, are not required to disclose comparative information as required by Chapter 7.1 for the financial year 2024. Other undertakings that are subject for the first time to reporting under ESRS based on the provisions of the CSRD are not required to disclose comparative information as required by Chapter 7.1 for their first reporting period. 

(new) ‘Wave-one’ undertakings may omit in their sustainability statement:  

Sustainability information is relevant when it may make a difference in the decisions of users under a double materiality approach (see Chapter 3).

Information may make a difference in a decision even if some users choose not to take advantage of it or are already aware of it from other sources. Sustainability information may impact decisions of users if it has predictive value, confirmatory value or both. Information has predictive value if it can be used as an input to processes employed by users to predict future outcomes. Sustainability information need not be a prediction or forecast to have predictive value but rather has predictive value when employed by users in making their own predictions.

Information has confirmatory value when it provides feedback about (confirms or changes) previous evaluations.

Materiality is an entity-specific aspect of relevance based on the nature or magnitude or both of the items to which the information relates, as assessed in the context of the undertaking’s sustainability reporting (see Chapter 3).

To be useful, the information must not only represent relevant phenomena; it must also faithfully represent the substance of the phenomena that it purports to represent. Faithful representation requires information to be (a) complete, (b) neutral and (c) accurate.

A complete depiction of an impact, a risk or an opportunity includes all material information necessary for the users to understand that impact, risk or opportunity. This includes how the undertaking has adapted its strategy, risk management and governance in response to that impact, risk or opportunity, as well as the policies and actions in place to manage it, and metrics identified to set targets and measure performance.

A neutral depiction is without bias in its selection or disclosure of information. Information is neutral if it is not slanted, weighted, emphasised, de-emphasised or otherwise manipulated to make it more likely that the users will receive that information favourably or unfavourably. It shall be balanced so as to cover favourable/positive and unfavourable/negative aspects. Both negative and positive material impacts from an impact materiality perspective as well as material risks and opportunities from a financial materiality perspective shall receive equal attention. Any aspirational sustainability information, for example, targets or plans, shall cover both aspirations and factors that could prevent the undertaking from achieving these aspirations in order to have a neutral depiction.

Neutrality is supported by the exercise of prudence, i.e. caution when making judgements under conditions of uncertainty. Information shall not be netted or compensated to be neutral. The exercise of prudence means that opportunities are not overstated and risks are not understated. Equally, the exercise of prudence does not allow for the understatement of opportunities or the overstatement of risks. The undertaking may present net information, in addition to gross values, if such presentation does not obscure relevant information and includes a clear explanation about the effects of the netting and the reasons for the netting.

Information can be accurate without being perfectly precise in all respects. Accurate information implies that the undertaking has implemented adequate processes and internal controls to avoid material errors or material misstatements. As such, estimates shall be presented with a clear emphasis on their possible limitations and associated uncertainty (see Chapter 7.2). The amount of precision needed and attainable, and the factors that make information accurate, depend on the nature of the information and the nature of the topics it addresses. For example, accuracy requires that:

Sustainability information is comparable when it can be compared with information provided by the undertaking in previous periods and can be compared with information provided by other undertakings, in particular those with similar activities or operating within the same sector. A point of reference for comparison can be a target, a baseline, a sector benchmark, comparable information from either other undertakings or from an internationally recognised organisation, etc..

Consistency is related to, but is not the same as, comparability. Consistency refers to the use of the same approaches or methods for the same topic from period to period by the undertaking and other undertakings. Consistency helps to achieve the goal of comparability.

Comparability is not uniformity. For information to be comparable, like components shall look alike and different components shall look different. Comparability of sustainability information is not enhanced by making unlike things look alike any more than it is enhanced by making like things look different. 

Verifiability helps to give users confidence that information is complete, neutral and accurate. Sustainability information is verifiable if it is possible to corroborate the information itself or the inputs used to derive it.

Verifiability means that various knowledgeable and independent observers could reach consensus, although not necessarily complete agreement, that a particular depiction is a faithful representation. Sustainability information shall be provided in a way that enhances its verifiability, for example, by:

Some sustainability information will be in the form of explanations or forward-looking information. Those disclosures can be supportable by faithfully representing on a factual basis, for example, the strategies, plans and risk analyses of the undertaking. To help users decide whether to use such information, the undertaking shall describe the underlying assumptions and methods of producing the information as well as other factors that provide evidence reflecting the actual plans or decisions made by the undertaking.

Sustainability information is understandable when it is clear and concise. Understandable information enables any reasonably knowledgeable user to readily comprehend the information being communicated.

For sustainability disclosures to be concise, they need to (a) avoid generic ‘boilerplate’ information, which is not specific to the undertaking; (b) avoid unnecessary duplication of information, including information also provided in financial statements; and (c) use clear language and well-structured sentences and paragraphs. Disclosures are concise if they include only material information. Supplementary information presented pursuant to Sub-Chapter 8.2 shall be provided in a way that avoids obscuring material information.

Clarity might be enhanced by distinguishing information about developments in the reporting period from ‘standing’ information that remains relatively unchanged from one period to the next. This can be done, for example, by separately describing features of the undertaking’s sustainability-related governance and risk management processes that have changed since the previous reporting period compared to those that remain unchanged.

The completeness, clarity and comparability of sustainability disclosures all rely on information being presented as a coherent whole. For sustainability disclosures to be coherent, they shall be presented in a way that explains the context and the connections between the related information. Coherence also requires the undertaking to provide information in a way that allows users to relate information about its impacts, risks and opportunities to information in the undertaking’s financial statements.

If risks and opportunities discussed in the financial statements have implications for sustainability reporting, the undertaking shall include in the sustainability statement the information necessary for users to assess those implications and present appropriate links to the financial statements (see Chapter 9). The level of information, granularity and technicality shall be aligned with the needs and expectations of users. Abbreviations shall be avoided and the units of measure need to be defined and disclosed.